FEES FOR TECHNICAL SERVICES

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..... they arise and according to the laws of that State, but if the beneficial owner of the fees for technical services is a resident of the other Contracting State the tax so charged shall not exceed 10 percent of the gross amount of the fees for technical services. 3. The term "fees for technical services" means payment of any kind in consideration for the rendering of any managerial, technica .....

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..... be, shall apply. 5. Fees for technical services shall be deemed to arise in a Contracting State when the payer is a resident of that State. Where, however, the person paying the fees for technical services, whether he is a resident of a Contracting State or not, has in a Contracting State a permanent establishment or a fixed base in connection with which the obligation to pay the fees for .....

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